Researchers and scientists who need a Plant Incorporated Protectant Experimental Use Permit, or PIP EUP, from the U.S. Environmental Protection Agency, should know that there are a few hoops to jump through. But just because the EPA is looking for specific pieces of information, doesn't mean that filling out your application for a PIP EUP should be difficult. Here are a few tips to improve your odds of approval.
Estimate your acreage
Any researcher should know the size and scope of the project that they're working on, but the EPA needs to know this too. According to the agency, the application should include the maximum acreage per state, in the entire study across state lines and the amount of acreage per state per study. Additionally, estimations should be made for expected growth as the study continues each year and the scope possibly increases.
Asking for specific acreage numbers or even estimates can be difficult before you even gain approval to begin your research, but the EPA outlined a few helpful aspects to consider in your acreage estimates to help improve the accuracy of your figures.
"It is recommended that calculations of PIP EUP acreage include all of the following: PIP test plants, including plants containing registered PIPs; non-PIP plants used for breeding purposes; non-PIP plants that are not intentional recipients of a PIP (e.g. isoline control plots); and associated border rows contained within the test block(s), including border rows which outline the perimeter of the test block(s)," the agency explained.
Explain clearly how you'll use the seed produced
A condition of the PIP EUP is that you can't sell any produce or plants used from experimental PIPs. However, you can use the seeds from these experiments in the same research in a later planting season. Clearly outline your specific needs, expressing that you're aware of the restrictions, but that you're also ready to use your own seeds to further the research.
Mark you exact locations and any changes
Although not specifically required, the EPA recommends that submissions explain the exact location where the experiments will take place as well as outline any changes to the original submission that occur. These additions to the application help the EPA know just a little bit more about what your research will be and show that you did your digging.
Talk before submitting
The EPA explained that before any researcher or team actually sends in their application, they should talk to a scientist in the Biopesticides and Pollution Prevention Division. The EPA can help answer any questions and clarify any confusion, ensuring that you're submitting the most complete application for a PIP EUP.
What is a PIP?
A PIP or Plant Incorporated Protectant is a form of genetic pesticide where plants are bred to produce pesticides within their own tissue. They are different than plants bred to resist treatment from herbicides, where farmers are able to spray their crops with herbicides without fear of killing the plant. PIPs instead take on the pest problem directly.
Compared to other pesticides, there are a small number of chemicals registered with the EPA as PIPs. Additionally, there's some evidence that pests can become resistant to these genetically modified crops, which hurts their effectiveness, Beyond Pesticides explained. This resistance that some pests experience in PIPs has led to many people re-adopting older pesticides again, giving 2013 a massive year in traditional pesticide sales.
The first PIP registered by the EPA was Bacillus thuringiensis for potatoes in 1995. It was designed by Monsanto, which has registered several PIPs subsequently. Bt has since been registered for a variety of crops.
